This register includes a list of Russian oligarchs from the rating “200 richest businessmen” made by Forbes.ru in 2021 as well as a number of other Russian “large businessmen,” who, according to the “War and Sanctions” portal of the National Agency for Prevention of Corruption, are beneficiaries of Ukrainian companies and, therefore, are under Ukrainian sanctions.
The goal of this register is to systematize the arrested and confiscated Russian assets in Ukraine.
Why this register was created
The need of such register was determined by the team of analysts of the Trap Aggressor project in 2022, when the newsfeed was already being filled with information about arrests of Russian companies in Ukraine, though it was next to impossible to identify and track down relevant processes. In many cases, news about arrests are replicated, names of companies often are not disclosed, with the register of ARMA arrested asses remaining closed for the general public. Ukraine launched the process of confiscation of assets under the Law of Ukraine on Sanctions in September of 2022. However, assets of only several Russians were confiscated, and clear priorities and goal of the confiscation were missing. For these reasons, the register will help to track down effectiveness of the process of confiscation.
Who is included in the register
We have chosen the list of the Russian Forbes because the richest Russians were added to it. Moreover, it is known that to make big money in Russia without connections with political elites is impossible.
We use the notion “oligarch” in the register for the reason that the bulk of persons in the register gained their wealth and political influence due to privatization of state assets in “the turbulent 90th”; connections with the Kremlin and disbursement of public funds. While describing each “entrepreneur”, we paid particular attention to his or her attitude towards the full-scale invasion into Ukraine, connections with politicians and engagement of their companies into cooperation with the military and industrial complex of the aggressor’s army. It is our firm belief that they must be held accountable for their support of the Russian regime’s actions.
Persons from the Russian Forbes who are not under Ukrainian sanctions and have nothing to do with Ukrainian assets have not been added to the register. Being on a sanction list of Ukraine testifies to responsibility of these persons for actions of the Russian regime and creates grounds for confiscation of property of such persons under the law on sanctions.
How we establish links to Ukrainian companies
We have found the following connections of Ukrainian companies with Russian beneficiaries:
- indication of a person or a Russian company connected with a person concerned as the final beneficiary of a Ukrainian company in the YouControl system
- evidence of officers of Ukrainian law enforcement bodies and justice bodies in criminal proceedings into connections between a Ukrainian company and Russian beneficiary
- descriptions of connections between a Ukrainian company and Russian beneficiary in journalistic investigations.
It is important to note that in many cases a beneficiary shares powers with business partners rather than owns 100% of a company. We indicated stakes of Ukrainian companies owned by the Russians in cards of assets in those cases where, along with our colleagues from YouControl, managed to determine these stakes. For this very reason, on some cards of assets and beneficiaries, there is information about shares and amounts of corporate rights owned by a beneficiary whereas it is missing on other cards.
How we calculate asset value
Similarly, we have estimated the total value of assets by amounts of statutory capitals of companies owned by their beneficiaries. It is worth remembering that corporate rights do not reflect real value of assets, though they are the source of consolidated all publicly accessible data for companies. The real value of assets by far exceeds the amount on the main page of this web site.
Asset statuses: arrest and confiscation
Statuses of assets are divided into arrested and confiscated.
Arrested assets
– companies and property which were arrested within criminal proceedings. Arrested asses, in turn, can be transferred into management of ARMA. Statuses of companies deal solely with recovery or arrest of corporate rights of companies as corporate rights enable to take part in management of a company and receive profit. We receive information about arrests and transfer into ARMA management from judicial decisions and news of the ARMA web site.
Confiscated assets
– companies and property forfeited in favour of the government by a decision of the Higher Anti-Corruption Court of Ukraine upon a request of the Ministry of Justice of Ukraine.
What’s next for the register
The Trap Aggressor team does not plan to stop solely on the Forbes list but will continue entering assets of persons responsible for the full-scale invasion of Russian into Ukraine into the register.
The goal is to determine Ukrainian assets which are linked to the Russians who have contributed into formation of the Kremlin aggressive regime whose beneficiaries have not been imposed sanctions on. It means that their assets can’t be recovered by the Ukrainian authorities.
Taking advantage of this opportunity, we would like to thank YouControl for the provided data and interns of Trap Aggressor, Oleksandra Temchenko and Andriy Brus, for their assistance in filling in the register!